A Performance Audit of Projections of Utah’s Water Needs

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REPORT TO THE UTAH LEGISLATURE Number 2015-01 A Performance Audit of Projections of Utah’s Water Needs May 2015 Office of the LEGISLATIVE AUDITOR GENERAL State of Utah

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Published by the State of Utah, May 2015

Transcript of A Performance Audit of Projections of Utah’s Water Needs

  • REPORT TO THE

    UTAH LEGISLATURE

    Number 2015-01

    A Performance Audit of Projections of Utahs Water Needs

    May 2015

    Office of the LEGISLATIVE AUDITOR GENERAL

    State of Utah

  • Office of the Legislative Auditor General

    315 HOUSE BUILDING PO BOX 145315 SALT LAKE CITY, UT 84114-5315 (801) 538-1033 FAX (801) 538-1063

    Audit Subcommittee of the Legislative Management Committee

    President Wayne L. Niederhauser, CoChair Speaker Gregory H. Hughes, CoChair Senator Gene Davis Representative Brian S. King

    JOHN M. SCHAFF, CIA AUDITOR GENERAL

    STATE OF UTAH

    May 2015 TO: THE UTAH STATE LEGISLATURE

    Transmitted herewith is our report, A Performance Audit of Projections of Utahs Water Needs (Report #2015-01). A digest is found on the blue pages located at the front of the report. The objectives and scope of the audit are explained in the Introduction.

    We will be happy to meet with appropriate legislative committees, individual legislators, and other state officials to discuss any item contained in the report in order to facilitate the implementation of the recommendations. Sincerely, John M. Schaff, CIA Auditor General JMS/lm

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    Digest of A Performance Audit of

    Projections of Utahs Water Needs

    The Division of Water Resources projections indicate that Utahs statewide demand for water will outstrip the currently developed supply in about 25 years. Some believe the state can address its growing demand for water through conservation and by developing local supplies, including the conversion of agriculture water to municipal use. Others believe the states growing demand for water will require the development of major new sources of supply that will cost billions of dollars. Considering the importance of water to the health, social and the economic well-being of our states residents, it is essential that the division provide the best possible data to guide water planning decisions.

    Our assignment was to determine the reliability of the divisions data in the figure shown below and assess the accuracy of the divisions projections of water demand and supply. We were also asked to review options for extending Utahs currently developed water supply.

    Figure 1. Utahs Projected Municipal and Industrial Water Demand and Supply. The division projects that the demand for water in Utah will exceed the current non-shared supply by about 2040.

    Source: Adapted from a Division of Water Resources figure.

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    Chapter II Reliability of Water Use Data

    Needs to Improve The Division Does Not Have Reliable Local Water Use Data. In order to effectively

    manage the states water resources and plan for future water needs, accurate water use data is critical. The Division of Water Resources relies on water use data submitted by local water systems to the Division of Water Rights as the starting point for projecting future water needs. Unfortunately, we found that the submitted data contains significant inaccuracies. State water agencies as well as local water systems operators also acknowledge these inaccuracies.

    The Division Needs an Improved Process for Ensuring Water Data Is Reliable. In response to the problems with water use data, the Division of Water Resources attempts to verify data accuracy and correct any mistakes by contacting all local water providers every five years. Besides this process being inefficient, we question the effectiveness of the divisions efforts to validate the data. The Department of Natural Resources needs to take a leading role in coordinating efforts between Division of Water Resources and The Division of Water Rights to improve the process of gathering accurate water use data. To support this effort, the legislature should consider giving the Division of Water Resources statutory authority to validate water use information from local water systems.

    We Question the Reliability of the Divisions Baseline Water Use Study. We also have concerns about the 2000 water study, which the division uses as a baseline to project Utahs future water needs. We could not confirm the studys results because of the lack of documentation of the source data and the steps used to prepare the report. In addition, the 2000 water study relies on a compilation of water studies performed between 1992 and 1999, which may not be representative of the year 2000. Finally, because secondary water systems are not typically metered, much of the reported outdoor water use is based on estimates.

    Chapter III Conservation and Policy Choices

    Can Reduce Demand for Water Conservation Will Lead to Less Water Use. We question the divisions projected

    demand for water, which assumes Utah residents will consume on average 220 gallons per day through the year 2060. The accuracy of this projection appears overstated for a number of reasons. First, the projected amount of water use, 220 gpcd, is based on a 2000 baseline water study, which, as described in Chapter II, may be unreliable. Second, other western states appear to use less water than Utah, indicating Utah residents may be able to further reduce their water use. Third, ongoing trends towards conservation should continue to

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    reduce per capita water use beyond the states 25 percent conservation goal. The division stated that they intend to update the state goal once it has been met.

    Some Regions Can Reduce Water Use More Than the Statewide Goal of 25 Percent. Some river basins have the ability to reduce water use well beyond the state conservation goal of 25 percent. In fact, two river basins already met that goal by 2010, and two other regions had nearly met the goal. This is another reason why we think the long-term projected use of 220 gallons statewide (as shown in Figure 1) is too high. Rather than applying the same 25 percent conservation goal to all basins, the division should work with local water providers to establish a new set of conservation goals that reflect each regions unique conditions and ability to conserve.

    State Policies on Metering and Pricing Can Affect Water Demand. Utahs relatively low water costs appears to contribute to higher per capita water use when compared with other states. Unless per capita water use is reduced, new, more costly sources of supply will need to be developed. As pressures on Utahs currently developed supply intensify, local and state policymakers will need to consider policy options to reduce demand, including universal metering and water pricing.

    One option is to require the metering of all water service connections including those for secondary water customers. Universal metering provides water managers with the data needed to effectively manage their systems. Metering can also be used to provide consumers with information regarding their use. Finally, metering allows water providers the ability to charge water users based on their actual use. The Legislature should consider adopting policies that will require the phasing in of universal metering.

    Policymakers should also consider the way water is priced in Utah. Utahs existing price structure does not adequately encourage conservation. For example, the use of property tax to subsidize the cost of water may lead to an increase in use. In addition, rather than using relatively flat pricing structures, water systems should adopt conservation pricing, or increasing block rates, to incentivize efficient water use. As shown in Figure 2, cities with block rate structures charge consumers an increasingly higher price as consumption increases. The Legislature should consider changes to pricing policies that will encourage efficient water use.

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    Figure 2. Comparison of City Water Rate Structures. A selected group of Utah Cities are shown to have flatter block rate structures when compared to those of other major western cities. More pronounced block rates tend to encourage conservation.

    Source: City Water Departments.

    Chapter IV

    Growth in Future Water Supply Should Be Reported to Policy Makers

    Division Projections Should Include Expected Local Water Development. The divisions projections of future water use do not include growth in the states water supply beyond what was already developed in 2010, with a few exceptions. Those exceptions include the additional supply from a few new water projects. In contrast to division projections, Utahs developed water supply will grow incrementally as agricultural water becomes available for municipal use and as municipalities develop their remaining sources of supply. By excluding much of the growth in local water supplies, the divisions projections accelerate the timeframe in which costly new water projects appear to be needed.

    Good Basin Plans Should Be the Basis for Better Statewide Planning. As with the statewide projections, most of the divisions basin plans do not estimate the growth in the regions water supply. The basin plans also understate the amount of agriculture water available for municipal use. We recommend the division update its basin plans on a more regular basis. We also recommend that they estimate the incremental growth in supply that will occur as municipalities develop additional sources of water.

  • REPORT TO THE

    UTAH LEGISLATURE

    Report No. 2015-01

    A Performance Audit of Projections of Utahs Water Needs

    May 2015

    Audit Performed By:

    Audit Manager Richard Coleman

    Audit Supervisor James Behunin

    Audit Staff Tyson Cabulagan Anndrea Parrish

  • Table of Contents

    Digest .................................................................................................................................. i

    Chapter I Introduction ....................................................................................................... 1

    Planning Utahs Water Future Is Increasingly Important ........................................... 1

    Questions about Accuracy of Divisions Projections Led to Audit Request ................ 6

    Audit Scope and Objectives ....................................................................................... 8

    Chapter II Reliability of Water Use Data Needs to Improve ............................................... 9

    The Division Does Not Have Reliable Local Water Use Data ................................... 9

    The Division Needs an Improved Process For Ensuring Water Data Is Reliable ...... 13

    We Question the Reliability of the Divisions Baseline Water Use Study ................. 18

    Recommendations ................................................................................................... 24

    Chapter III Conservation and Policy Choices Can Reduce Demand for Water ................. 25

    Conservation Will Lead To Less Water Use ............................................................ 25

    Some Regions Can Reduce Water Use Beyond the Statewide Goal of 25 Percent ... 31

    State Policies on Metering and Pricing Can Affect Water Demand .......................... 35

    Recommendations ................................................................................................... 44

    Chapter IV Growth in Future Water Supply Should Be Reported to Policy Makers ......... 47

    Division Projections Should Include Expected Local Water Development ............... 47

    Good Basin Plans Should Be the Basis for Better Statewide Planning ...................... 51

    Recommendations ................................................................................................... 55

    Appendices ....................................................................................................................... 57

    Appendix A ............................................................................................................. 59

    Appendix B ............................................................................................................. 63

    Agency Response ............................................................................................................. 67

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    Chapter I Introduction

    Water is a vital resource that is essential to the health, social and economic well-being of the every resident in the state of Utah. It is also becoming an increasingly scarce resource. By 2060, the states population is projected to double to nearly 6 million people. This jump in population will strain our currently developed water supply, which has sparked a debate about the need and time frames for developing additional sources of supply. Careful management and planning is critical for ensuring a reliable water supply for future generations.

    Although most water use in Utah is for agriculture, this report only addresses Utahs municipal and industrial (M&I) water needs. To avoid future M&I water shortages, state and local water managers project that Utah will need to spend $33 billion1 over the next several decades to repair existing water systems and add additional supply. These costly investments have prompted the Legislature to ask our office to evaluate the accuracy of the states projected demand and supply for water and to investigate options for extending Utahs currently developed water supply.

    Planning Utahs Water Future Is Increasingly Important

    Planning is becoming increasingly important for identifying and evaluating options for meeting Utahs future water needs. The Division of Water Resources (the division) is the states water planning authority. The division predicts that water demand by Utahs growing population will exceed the states currently developed water supply sometime around 2040. However, questions have been raised regarding the accuracy of the divisions predictions. This debate highlights the need for a more sophisticated approach to forecasting Utahs future water needs.

    1 Prepare 60, Statewide Water Infrastructure Plan

    State and local water managers project that Utah will need to spend $33 billion to repair existing water systems and add additional supply.

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    Utahs Population Is Expected To Grow to 6 Million by 2060

    The division uses population projections to plan for Utahs future water needs. According to population projections prepared by the Governors Office of Management and Budget (GOMB), Utahs population will double by 2060 to nearly 6 million people, as shown in Figure 1.1.

    Figure 1.1 Utahs Projected Population. Utahs population is expected to double to 6 million by 2060.

    Source: Governors Office of Management and Budget

    Much of this growth is expected to occur in urban areas along the Wasatch Front, resulting in more dense living arrangements, which could lower per capita water use. GOMBs population projections assume water availability will not constrain growth.

    The Division Is the States Water Planning Authority

    Comprehensive water planning is one of the divisions primary responsibilities. The Utah Code 73-10-18 describes the Division of Water Resources as the water resource authority for the state and gives the director authority to make studies, investigations, and plans for the full development and utilization and promotion of water and power resources of the state. Furthermore, the division reports its mission is to plan, conserve, develop and protect Utahs water.

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    Comprehensive water planning is one of the divisions critical responsibilities.

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    The division has a challenge to balance the competing elements of its mission. To some extent promoting the full development and utilization of water in the state is at odds with promoting conservation. In fact, in a legislative committee, one member questioned whether Utah should wait to promote conservation until after the state has developed its full allocation of interstate waters. Other policymakers hold the competing view that more focused conservation efforts are needed before investing in large-scale infrastructure projects. It was beyond our audit scope to consider such issues. Instead, we focused on the divisions planning role including estimates of future water demand and supply.

    To fulfill this planning objective, the division has prepared a number of documents, including a statewide water plan as well as individual water plans for each of the states eleven major hydrologic river basins. These documents identify water use trends and make projections about future water demand.

    Division Projections Indicate Utahs Current Water Supply Will Not Meet Future Water Needs

    The divisions analysis indicates Utahs demand for water will outstrip its currently developed supply in about 25 years. Figure 1.2 shows the graphic used by the division to illustrate potential water shortages. The important aspects of Figure 1.2 are explained in the bullets below.

    This audit focuses on the divisions planning role including estimates of future water demand and supply.

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    Figure 1.2 DWRe Analysis of Utahs Projected M&I Potential Water Demand and Supply. The Audit Subcommittee directed auditors to review the reliability the divisions analysis.

    Source: Division of Water Resources

    Figure 1.2 is somewhat confusing with two different vertical scales and a non-linear horizontal scale. However, the main points of interest are as follows:

    Projected water demand. The red line shows projected water use without conservation. It is based on estimated use of 293 gallons per capita per day (gpcd) in 2000. The blue line shows projected water use with conservation. It assumes a gradual reduction in water use to 220 gpcd in 2025 (25 percent conservation goal), with no further reductions thereafter.

    Water supply. The blue area shows the states currently developed reliable M&I supply of water. Unlike demand, growth in supply is not projected. The currently developed supply includes some growth for four large water conservancy districts. However, all other water providers supply is held constant at 2010 levels. The blue shaded area above the dashed purple line shows supply that cannot be shared from one region to another.

    The statewide demand for water is projected to exceed the currently developed non-shared supply of water by 2040.

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    Projected water shortages. The brackets on the right side of the figure show the benefits of conservation and the difference between projected demand and the non-shared supply. The figure also shows that, even with conservation, there will be a water shortfall of 371,000 acre-feet per year in 2060. The vertical bars show the estimated number of local water entities that are projected to run out of water at various times in the future.

    While everyone agrees that Utah cannot afford to run out of water, the situation portrayed by the division in Figure 1.2 has led to differences of opinion regarding how to meet Utahs future water demand. One viewpoint is that through increased conservation, the development of local water projects, and the conversion of agriculture water to municipal use, the state should be able to accommodate the water needs of its growing population. Contrasting views hold that these actions alone will not meet the states growing water needs and that major water development projects are necessary. The division has stated that conservation, agricultural conversion, and water development are needed to meet the states growing water demand.

    In fact, the division is statutorily charged with planning for the development of two large-scale water projects: the Lake Powell Pipeline and the Bear River Project. Existing interstate compacts grant Utah more water than is currently developed so the projects contribute to the divisions goal to defend and protect Utahs rights to develop and use its entitlement to interstate streams. The estimated cost of these two projects alone is $2.5 billion. The huge expense of the proposed projects highlights the need for a reliable forecast of water demand and supply.

    Detailed analysis of basin level information would have been required for us to evaluate the need for these two major water projects, which was beyond the scope of this audit. Instead, our assignment was to assess the accuracy of state-level data presented to policymakers by the division.

    The division projects a water deficit of 371,000 acre-feet in 2060.

    The estimated cost of Utahs two major proposed water projects totals $2.5 billion.

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    Questions about Accuracy of Divisions Projections Led to Audit Request

    In response to requests for costly, large-scale water development projects, legislators asked for an audit of the accuracy of the divisions projections of demand and supply. Specifically, House of Representatives leaders asked that we review the reliability of data used to make predictions that look out 20 and 40 and 50 years into the future. Senate leaders asked that we review whether the division had adjusted its projections to reflect development being more dense that it was years ago. Other legislators asked whether the state is making adequate progress towards conservation and whether the division is considering future conversions of agricultural water to M&I use.

    Is the Data Used to Predict Utahs Future Water Needs Reliable?

    Division projections of future water demand rely on the divisions estimate of the states municipal and industrial water use in 2000. This baseline study reported that the average annual amount of water used by residential, commercial, industrial, and institutional water users in the year 2000 was 293 gallons per capita per day (gpcd). Because projections of future water demand are based on 293 gpcd, it is important that this per capita water use rate is accurate. If 293 gpcd is not accurate, then it casts doubt on the reliability of the projections derived from it. For this reason, verifying the accuracy of the 2000 baseline study was one of our primary audit objectives.

    Has the Division Fully Considered Water Conservation?

    Data published in national sources suggest that Utah residents consume relatively large amounts of water when compared to other states. Such comparisons should be regarded with caution. According to the US Geological Survey, state water use data will have varying levels of accuracy due to the differences in how each state accounts for their water use. In a 2010 US Geological Survey report, Utah has the second highest rate of residential water use. Figure 1.3 describes the results of state-level water use.

    Legislators have expressed concern over the accuracy of the Division of Water Resources projections.

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    Figure 1.3 United States Domestic Water Use in 2010. Utahs combined indoor and outdoor water use exceeds nearly every other state.

    Figure 1.3 shows that Utahs per capita residential water use (which does not include commercial, industrial, and institutional uses) was 167 gpcd in the year 2010. Utah was second only to Idaho at 168 gpcd, suggesting that our state can better manage its water use. Legislators specifically asked us to examine the states efforts to reduce water demand through conservation.

    Is Agricultural Water Available for Alleviating Water Supply Shortages?

    Agricultural water has the potential to address some of Utahs future M&I water needs. Utah does not actively pursue a policy of transferring agriculture water rights to cities that are in need of water. However, as land is converted from farms to urban development, the water rights attached to the farmland are typically made available for M&I uses. Figure 1.4 shows that agriculture, at 82 percent, is the largest user of the states developed water supply.

    Utah residents consume more water than residents in other Western states.

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    Figure 1.4 Utahs Agricultural, Municipal, and Industrial Water Use. The vast majority of the states developed water is used for agricultural purposes.

    Source: Division of Water Resources

    Agriculture water, once made available, could become a significant source of new water for municipal and industrial use. Legislators have asked if the divisions projections fully account for this source of additional water supply.

    Audit Scope and Objectives

    Members of the Legislative Audit Subcommittee asked for a performance audit of the Division of Water Resources. Their primary concern was that we verify the accuracy of the divisions projections of Utahs future water needs. The committee also requested that we investigate whether division projections account for the potential effects of water conservation and the conversion of agricultural water as options for extending and increasing our states water supply. Our response to these audit issues are addressed in the following chapters:

    Chapter II Reliability of Water Use Data Needs to Improve Chapter III Conservation and Policy Choices Can Reduce

    the Demand for Water

    Chapter IV Growth in Future Water Supply Should Be Reported to Policy Makers

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    The majority of the developed water in the state is used for agricultural purposes, a portion of which could be made available to meet future municipal water needs.

    The primary audit objective was the accuracy of the divisions projections of Utahs future water needs.

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    Chapter II Reliability of Water Use Data

    Needs to Improve

    Accurate water use data is essential for water management, planning, and policy decisions. State policy makers need assurances that when they support costly, large-scale water projects, the need for additional supply is real and the states investment is sound. The Division of Water Resources (the division) uses the Division of Water Rights data as the foundation for its analysis of the states water use. However, water use data reported by public water systems to the Division of Water Rights contains significant inaccuracies. While the division strives to verify the accuracy of the data before using it in its planning process, a lack of documentation and changes in methodology raise doubts about the reliability of the divisions water use studies.

    According to Utah statute, "All waters of this state, whether above or under the ground, are hereby declared to be the property of the public." In order to protect the publics interest, the state is dedicated to a) conserving its scarce water resources, b) providing adequate water supplies, c) ensuring the availability of the states streams for meeting its needs, and d) controlling its water resources. To meet these objectives accurate water data is critical. Unfortunately, the accuracy of Utahs water use data is not commensurate with its importance to the divisions planning effort and needs to improve.

    The Division Does Not Have Reliable Local Water Use Data

    In order to effectively manage the states water resources and plan for future water needs, accurate water use data is critical. The Division of Water Resources relies on water use data submitted to the Division of Water Rights as the starting point for projecting future water needs. Unfortunately, we found that the data submitted to the Division of Water Rights contains significant inaccuracies. State water agencies as well as local water systems also acknowledge these inaccuracies.

    The accuracy of Utahs water use data is not commensurate with its importance to the divisions planning effort and needs to improve.

    Chapter II reviews the reliability of Utahs water use data.

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    Division of Water Resources Relies on Water Use Data Submitted by Water Providers to the Division of Water Rights

    The Division of Water Rights collects water use data from public water providers throughout the state of Utah. This data is used by many state and federal water agencies for a variety of purposes, which includes water resource studies and water policy decisions. Our review revealed significant inaccuracies in the water use data reported by local water entities.

    Division of Water Rights Is the Primary Source for Water Use Data in Utah. Each year, the Division of Water Rights submits a water data form to all 468 community public water providers throughout the state requesting information about their water use. The data form requires public water providers to submit information regarding the monthly amount of water diverted from each water source, the monthly amount of water billed, and other water system information. This water use form is the primary source of data used by the Division of Water Resources for water planning purposes.

    Figure 2.1 Flowchart of Local Water Use Data. The Division of Water Rights collects water use data from public water providers and shares this data with other state water divisions as well as U.S. Geological Survey.

    As shown in Figure 2.1, data from public water providers is compiled by the Division of Water Rights and shared with the Division of Water Resources, the Division of Drinking Water, and U.S. Geological Survey for each agencys specific data needs.

    Unfortunately, the submitted data is subject to inaccuracies. The Division of Water Rights website reads, In many cases the data submitted by water providers are estimated and the reliability of these

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    The Division of Water Rights collects annual water use data from all 468 public water providers in the state and shares this data with other water agencies.

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    data are unknown. The next section will discuss some of the data errors we encountered in our audit tests.

    Local Water Use Data Contains Significant Inaccuracies

    Our review of local water use data revealed significant errors. Some errors were obvious. Some local water systems reported large swings in their water use, indicating that the data was not reliable. For example, one citys reported water use data in 2013 was more than double the amount reported for 2012. We also surveyed the data for inconsistencies and found a number of specific examples of data inaccuracies. For example, instead of reporting total metered use as recorded at each connection, the city reported its total source production at the well, which was a much higher figure. We also found several instances in which the water use data reported to the Division of Water Rights did not match the amount reported in other, internal city reports. Additionally, one citys reported water use for 2012 was the water use of another city with an identical name in the state of New York.

    After detecting the above data errors, many local and state water managers told us that they found the data submitted to the Division of Water Rights unreliable. For this reason, we concluded that it was not necessary for us to conduct a systematic review of the data. As the following section suggests, it is widely recognized that there are fundamental problems with the way the states water use data is gathered and submitted by local water providers.

    State Water Agencies and Local Water System Operators Know Water Use Data Is Unreliable

    Management in the Division of Water Rights, The Division of Water Resources, and the Division of Drinking Water validated our concerns with the reliability of the states water use data. They told us that the data is unreliable. Many local water system operators also reported concerns about the accuracy of the water use data.

    State Water Agencies Participate in the Annual Water Use Surveys But Do Not Trust the Data. Management from all three agencies expressed concern about the accuracy of the water use data. For example, the Division of Water Resources stated, the data received by the Division of Water Rights was simply not accurate

    Our review of local water use data revealed significant errors. For example, one citys reported water use for 2012 was sourced to a city with an identical name in the state of New York.

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    enough to make sound future water planning decisions. For this reason, the Division of Water Resources has attempted to compile more accurate water use data since the early 1990s.

    The Division of Drinking Water stated that the data collection process invites inaccurate data. When asked about the cause of these inaccuracies, the manager responsible for overseeing the reporting function at the Division of Water Rights acknowledged that they have not devoted sufficient resources towards monitoring the accuracy of the reports, correcting mistakes, and auditing local water system data.

    Local Water Systems Report Concerns with the Process for Collecting Water Use Data. We contacted staff at a number of water systems about their process for submitting water use data. These discussions revealed several reasons why local entities are not submitting accurate water use reports.

    The purpose of the data and instructions for collecting the data are unclear. Staff at several water systems we contacted reported that they were unclear about how the data is used. Consequently, it appears the reporting process is not always taken seriously. They also reported that the instructions are inadequate and subject to misinterpretation.

    Feedback is not provided when errors are identified. Water systems operators reported that they did not receive any feedback after submitting the data. As one water system operator stated, We would like to know if the submitted data is inaccurate or incomplete.

    The person responsible for submitting the data does not always have the training or expertise to report the data accurately. For example, one water system manager explained that large differences in their water use from one year to the next were due to misunderstandings by city staff regarding how to interpret the citys water metering systems.

    There is a perception that a citys unused water rights may be revoked. Municipalities may intentionally overstate their water use because they are concerned that if they do not report using their full allotment of water rights, the state engineer may someday revoke any unused rights. Although state law allows cities to retain

    Division of Water Rights acknowledges that they do not have sufficient staff to monitor accuracy of water use data.

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    their unused water rights to meet future water needs, this perception could add to data inaccuracies.

    Given the concerns raised by local water systems staff, it is not surprising that state agencies and other interested parties consider the data submitted to Division of Water Rights unreliable. The following section will discuss the validation process the division uses to improve the reliability of the states water use data.

    The Division Needs an Improved Process For Ensuring Water Data Is Reliable

    In response to the problems with water use data, the Division of Water Resources attempts to verify data accuracy and correct any mistakes by contacting all water providers every five years. Besides this process being inefficient, we question the effectiveness of the divisions efforts to validate the data. The Department of Natural Resources needs to take a leading role in coordinating efforts between Division of Water Resources and The Division of Water Rights to improve the process of gathering accurate water use data. To support this effort, the Legislature should consider giving the Division of Water Resources statutory authority to gather water use information directly from local water providers.

    Unreliable Water Use Data Has Resulted In an Inefficient Verification Practice

    Because the Division of Water Resources cannot rely on the Division of Water Rights water use data, they have developed a process for verifying the data. The process involves contacting nearly every regulated drinking water systems in the state, every five years, in each of the 11 hydrological basins to verify the accuracy of submitted data and to obtain data from water systems that did not submit use data. This verification process is inefficient. A better process would be to ensure that the data submitted by water providers is accurate to begin with and is reviewed on an annual basis.

    The effectiveness of the divisions data verification process is also a concern because much of the submitted data is accepted at face value. The division reports that if a water system states that its data is accurate and appears reasonable, then the division has no other alternative than to accept that data. The problem with this approach

    The Division of Water Resources uses an inefficient practice of contacting individual water systems to verify water use data.

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    is that inaccurate data can still be submitted. Another concern is that by verifying the data every five years, the division is unable to perform annual trend analysis, which would help in detecting inconsistencies in water use from year to year. The following figure illustrates the value of annual data.

    Figure 2.2 One City Reported Large Differences in Water Use From One Year to the Next. Over a period of just a few years, one citys reported water use went from 9000 acre-feet to just 3000 acre-feet. This type of information led us to question the reliability of the data submitted to the Division of Water Rights.

    Source Division of Water Rights.

    Figure 2.2 shows how annual water use data can help the division to identify inconsistencies in the data from year to year. This citys large swings in water use indicated something was wrong with their data. We asked the citys Public Works Director to explain the extreme volatility in his citys water use numbers. He told us that for several years before he was hired there were serious problems with the way the staff were reporting the citys water use. He recommended that we not trust any of the data submitted prior to the year 2009. Nonetheless, the division did not recognize the problems with the data and used it in their 2000, 2003, 2005 and 2010 M&I studies. Had the division reviewed the data year by year, they too would have been alerted to the problems with the data. The following section discusses the need for the division to work with local entities to improve the accuracy of the data they submit.

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    One city reported large swings in its water use indicating something was wrong with their data.

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    The Department of Natural Resources Can Improve Data Accuracy by Working with Local Entities

    The Division of Water Resources and the Division of Water Rights both acknowledge that the accuracy of the data reported by local water systems must improve. Since our audit focused on how water use data is incorporated in the Division of Water Resources plans, we think that the division should have a role in ensuring data is accurate. However, both divisions, as well as the Department of Natural Resources managers told us they think data collection should remain primarily the responsibility of the Division of Water Rights.

    Regardless of which division collects the data, we think the Department of Natural Resources should develop a way to ensure accurate data is collected. First, local water managers should be held accountable for submitting accurate data by signing off on the water use form. Second, a greater effort should be made to verify the accuracy of the data as it is received. Third, water use data should be compared with local sources of data such as a water system master plan, rate study, or impact fee study to identify and resolve data inconsistencies. Finally, audits can be used to validate and educate local entities about accurately collecting and reporting water use data.

    Local Water Managers Should be Held Accountable for Submitting Accurate Water Use Data. In recognition of the need for more accurate data, managers from the three state water agencies began a working group this past year resulting in several recommendation for improvements to the water use form and collection process. The proposed form would require water system personnel with direct knowledge of flow measurements collect the data and fill out the form. This person would certify that the information is correct, sign the report, and provide their water operator certification number. By placing their professional credentials on the line, local water operators may take greater responsibility for the accuracy of the data they submit. We support this approach and recommend that this change in reporting process be implemented.

    The new focus on accountability should improve the quality of the information reported by local entities. This effort should also be combined with an effort to better educate local water managers regarding the importance of submitting accurate data.

    By placing their professional credentials on the line, local water operators may take greater responsibility for the accuracy of the data they submit.

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    The Division of Water Resources Should Do More to Identify Inaccuracies in the Water Use Data. Although the Division of Water Resources says it verifies the data before using it, we found that some of the errors in the Division of Water Rights data had been included in the M&I studies. This suggests the division needs to develop additional methods for efficiently verifying water use data.

    To test for errors in the divisions water use reports, we examined those water systems that experienced extremely large drops in water use from 2005 and 2010. We found inaccuracies in the data reported for several of these water systems. For example, the division reported a 48 percent decline in American Fork Citys water use between 2005 and 2010. We discovered that this decline was due to the installation of a new pressurized irrigation system. Since water systems are not required to report secondary water use, which is generally unmetered, American Forks reduced use of its culinary system reflected the increased use of that separate, secondary system for its outdoor watering.

    Although the division contacted American Fork City to verify their data, this effort to verify the data did not uncover that citys actual water use. Instead of declining by 48 percent, the data we obtained from the city suggests water use actually increased after residents began to use the secondary water system. The amount of increase is unclear because we do not have an accurate estimate of past secondary water use in American Fork City.

    This example indicates that more validation efforts are needed to ensure accurate water use data. Evaluating water use data every five years, as is currently done, is not sufficient for identifying unusual data trends during the intervening years. Instead, by analyzing an entitys water use annually, the division would be more likely to spot errors in the data and identify entities needing follow-up contact.

    Inconsistencies with Locally Reported Data Should Be Identified and Resolved. Another method for testing water use data for errors is to compare the data with a variety of sources such as an entitys water master plan, water conservation plans, rate study, or impact fee study. By comparing the data with municipal plans and studies, we identified several inconsistencies.

    For example, by comparing Sandy Citys 2010 Water System Master Plan with the divisions water reports we found a mismatch in

    Evaluating water use data every five years, as is currently done, is not sufficient for identifying unusual data trends during the intervening years.

    Although the Division of Water Resources says it verifies the data before using it, we found errors that were included in the reports they use for planning purposes.

  • Office of the Utah Legislative Auditor General - 17 -

    the reported data. In some years, the difference was small, but in 2010, the difference was significant. In 2010, the division reported that Sandy City residents used 208 gpcd. The citys internal reports show a 12 percent difference in per capita water use at 234 gpcd. This discrepancy highlights the need for better controls, including a comparison of locally reported data to check for inconsistencies.

    Validity Checks, Audits, and Training Should Be Used to Improve the Accuracy of Locally Reported Data. Local entities have the option of submitting water use reports online. With a few improvements to the programming, the online form could be used to validate the data as it is entered and to check for errors in the data. For example, we found that Salt Lake Citys reported 2013 water use was more than double the amount reported for prior years. This error would have been caught as it was entered into the system, if a validation feature had been included in the online form.

    Periodic audits of water use data can also improve the accuracy of reporting by pinpointing errors. When data errors are found, through either validity checks or audits, staff can visit local entities and provide training to improve their reporting practices. Additionally, the division could use local water conferences to provide training to local water systems on how to accurately report water use data.

    More Resource Need to Be Dedicated to Collecting and Analyzing Accurate Water Data Annually. Currently, the Division of Water Rights has one staff person responsible for overseeing the reporting of local water use data. This person acts as an educator and auditor by attempting to obtain accurate water use data and by verifying the accuracy of the data. This is not a sufficient level of investment. To improve data reliability, which is essential for water management and planning, the Department of Natural Resources needs to devote more staff and resources to the states water use database. A request to the Legislature for additional resources will be necessary to satisfy this important objective.

    Division of Water Resources Should Be Given Statutory Authority to Validate Water Supply and Use Data

    While Utah Code 73-10-15 requires state agencies to cooperate with the Division of Water Resources in the formulating their state water plan, the division does not collect its own water use data. Instead, the Division of Water Resources relies on the Division of

    When data errors are found, through either validity checks or audits, staff can visit local entities and provide training to improve their reporting practices.

    The Division of Water Resources does not have statutory authority nor have they adopted administrative rules requiring local water systems to submit water use data.

  • A Performance Audit of Projections of Utahs Water Needs (May 2015) - 18 -

    Water Rights to gather the data it needs to perform its statewide planning responsibilities. The Division of Water Resources cited their lack of regulatory authority as one reason that they must accept data submitted by each water system. They said, the only verification that [the division] can do is utilize its engineering personnel and expertise to question some of the submitted data that looks suspect.

    Because gathering accurate water use data is essential for managing and planning purposes, we recommend that the Legislature consider granting the Division of Water Resources statutory authority to validate the data submitted to the Division of Water Rights. Requiring local entities to submit accurate data should not be overly burdensome, as they should already be generating this information for their own purposes. The Division of Water Resources should have a role in improving this important data.

    We Question the Reliability of the Divisions Baseline Water Use Study

    In addition to our concerns about the source data, we also question the reliability of the divisions 2000 M&I study. One concern is the lack of documentation of the methods used to prepare the report. In addition, the 2000 water study does not include any data for 2000, which is acknowledged in their report. Instead, the report consists of data from studies conducted during the prior eight years. Finally, because secondary water systems are not metered, much of the reported outdoor water use is based on estimates.

    After issuing its 2000 M&I study, the division began to improve its methods for reporting water supply and use in the state. While the 2010 M&I study showed marked improvements in its methodology, the division still uses the 2000 study as the baseline for estimating future water use and evaluating the states conservation efforts. We believe good data and a sound methodology should be used in studies that drive projections of future water use in the state.

    While the divisions methods for estimating water use have improved in recent years, it still relies on its 2000 M&I study as a baseline for evaluating the states conservation efforts.

  • Office of the Utah Legislative Auditor General - 19 -

    Methods Used to Prepare Baseline Report Are Poorly Documented

    Division staff were unable to adequately document their methodology or provide source documentation for the data used in their baseline 2000 M&I report. According to one division manager, some staff members in the past just entered M&I use data into a spreadsheet as they would talk to people on the phone. Therefore, the manager reports the source data was not documented. Division management stated that while they trusted staff to enter the correct data, the accuracy of the study depends on the ability of local water system staff to report the data accurately.

    Because division staff were unable to document the source of the data used in their baseline study, we could not verify the accuracy of the reported data. Additionally, the methodology used was also difficult to document. For example, the division requires its staff to estimate the amount of secondary water used by some entities. However, without documentation of the methodology, we were unable to verify whether a reasonable and consistent method was used to estimate secondary water use. In addition, without proper documentation, the divisions managers and supervisors would have been unable to verify if staff followed consistent procedures as they gathered the data.

    2000 Baseline Study Contains Data That May Not Be Representative of 2000

    The divisions 2000 baseline study includes water use data from reports that span a period of seven years between 1992 through 1999. Variability in the weather and growing conservation efforts over these years, suggests that prior basin studies may not be representative of water use in 2000.

    The divisions 2000 baseline study acknowledges that the data used in the study was a combination of basin studies performed during the prior eight years. The preface of the 2000 study states:

    The Municipal and Industrial Water Supply Studies were completed for the eleven hydrologic basins with data collected for 1992 and up to the year 2000 from each of the over 450 water systems of the state. This statewide summary is a compilation of the data and can

    The 2000 M&I study is based on data from 1992 through 1999, which may not be representative of water use in 2000.

    Division staff were unable to document their methodology or provide us with source documentation for the data used in their baseline 2000 M&I report.

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    be considered, for reference purposes, to be representative of the statewide municipal and industrial water usage for the calendar year 2000.

    Although the statement up to the year 2000 suggests some of the data gathered was from 2000, we verified that all the data used in the study came from prior studies from 1992 through 1999. Even so, the division concluded that the basin studies conducted during the prior eight years were representative of the states water use during 2000 and a per capita use of 293 gallons per day was reasonable. They said one reason they felt confident in their results was that 293 gpcd closely matches similar figures reported for Utah during the year 2000 by U.S. Geological Survey. However, the U.S. Geological Survey told us that their figures were based on the water production in the state, not metered use, and that the source production is normally higher than the use.

    We question whether prior water studies are representative of the usage for the calendar year 2000. For example, water use data for Davis, Morgan, and Weber counties was gathered in 1992 but reported as if it were the use in 2000. During the eight years the data was gathered, the increased use of low flow appliances and a growing interest in water conservation should have led to a decline in water use. In fact, the divisions own studies show a decline in potable water use of 6 percent between 1992 and 2001. In addition, during the 1990s, there was variability in the average temperature and rainfall from year to year, which would have affected outdoor water use. This variability in the weather in addition to growing conservation efforts suggest that prior basin studies may not be representative of the water use in 2000.

    The divisions use of the 2000 study as a baseline measure is important for understanding of each river basins performance. For example, in 2010, the division reported that the Weber River Basin had reduced its water use by 24 percent. That is a remarkable achievement in just ten years. However, it appears to be less of an accomplishment once we understand the reduction in water use actually occurred over 18 years.

    The divisions own studies show potable water use declined by 6 percent between 1992 and 2001.

  • Office of the Utah Legislative Auditor General - 21 -

    Secondary Water Is Estimated Due to a Lack of Metered Data

    Due to the lack of metered data, the need to estimate secondary water use and the changes in methodology over the years, the accuracy of some of the divisions secondary water use estimates are questionable. Swings in the water use figures described for the Weber River Basin are typical of many communities whose secondary water use was estimated by the division.

    Secondary Water Use Is Based Largely on Estimates Rather than Actual Metered Water Use Data. More than half of Utahs public water systems offer secondary water. In about 30 percent of the systems, secondary water is the primary source of outdoor irrigation water. Secondary water connections are typically not metered and users often receive unlimited use for a flat fee. Because most secondary water use is unmetered, the division relies on its staff to estimate the amount of secondary water used in each community. This practice means about 23 percent of the water use reported by the division is not based on actual data but on staff estimates.

    Changes in Methodology Undermine the Accuracy of Unmetered Water Use Estimates. An evolving methodology for estimating secondary water use has resulted in large swings in the reported data. The water use data reported for the Weber River Basin offers a good example of how changes in the methodology can affect water use estimates. The data, shown in Figure 2.3, shows large swings in secondary water use from one study to the next.

    Secondary users are generally charged a flat rate for unlimited water use because secondary water is typically unmetered.

  • A Performance Audit of Projections of Utahs Water Needs (May 2015) - 22 -

    Figure 2.3 Estimates of the Weber River Basins Secondary Water Use Show Inconsistencies. The reported secondary water use, which is not metered, shows large swings in the data.

    Source: Division of Water Resources 2000, 2005, 2010 Municipal and Industrial Water Supply and Use Studies. *Weber River Basins data for the 2000 M&I study was gathered in 1992.

    Figure 2.3 shows the divisions estimates of Weber Basins secondary water use over the years. According to the divisions estimates, secondary water use increased 28 percent in 2005 and then declined 39 percent in 2010. Because these numbers are not based on actual metered data, are not affected by wet or dry years or by changes in the population served, we attribute these swings to changes in the methodology used to estimate secondary water use. Such large swings are common in the divisions water use studies, casting doubt on the accuracy of the divisions secondary water data.

    Methods Used for Estimating Secondary Water Add Uncertainty in the Accuracy of Utahs Water Use Projections. Figure 2.4 is a chart often used by the division to show the states progress toward its water conservation goal. The goal is to reduce water use at least 25 percent below the level of use in 2000 by 2025.

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    Estimates of secondary water in Weber Basin show large swings in water use due to methodological changes.

  • Office of the Utah Legislative Auditor General - 23 -

    Figure 2.4 Utahs Water Use Since 1990. Volatility in the reported secondary water use raises doubts about the comparability of past water studies. It also raises questions about the accuracy of the report that water use has declined by 18 percent from 2000.

    Source: Division of Water Resources

    Figure 2.4 shows large fluctuations in secondary water use (shown in blue) during 2000, 2005, and 2010. It shows that the secondary water use in 2000 was 55 gpcd. This is the difference between year 2000s total water use of 293 gpcd and the potable use of 240 gpcd. In 2005, that reported secondary water use rose to 70 gpcd. Then it declined to 55 gpcd in 2010. These swings in the reported use are explained, in part, by the use of different methods to estimate secondary water use.

    Over the years, the division has improved its methods for estimating secondary water use. We believe the most recent estimates are more accurate than prior year estimates. Unfortunately, by changing the methods used, the division has made it difficult to compare the results of different M&I studies. For example, Figure 2.4 shows that from 2000 to 2005 secondary water use increased 27 percent from 55 to 70 gpcd at the same time that potable use declined by 21 percent from 240 to 190. These results suggest contradictory trends in water use. Due to concerns about changing methodologies, we do not know the extent to which the changes in reported use were due to the new estimating methods or whether they were due to actual changes in water use.

    Over the years, the division has improved its methods for estimating secondary water use.

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    A consistent methodology and accurate water use data are both necessary to prepare a reliable baseline estimate of the states future water demand. The current projections are based on a 2000 M&I study which indicates that water was used at a rate of 293 gpcd. Due to concerns with the accuracy of the source data as well as methodology used, we cannot validate the accuracy of 293 gpcd or the projections of future water demand, which is as discussed in the next chapter.

    Recommendations

    We recommend that the Division of Water Resources review water use data annually to perform trend analysis.

    We recommend that the Department of Natural Resources work with state water agencies to develop an efficient and effective system of collecting accurate water use data from public water providers. Methods that should be considered include:

    a. Making local water managers responsible for submitting accurate water use data more accountable by requiring them to sign their report and identify their position and credentials.

    b. Incorporating a routine data edit check feature in the online data collection form that is used to validate the accuracy of the data submitted by public water providers.

    c. Validating the accuracy of water use data by comparing it to other sources with similar information.

    d. Conducting data validity checks, periodic audits, and training of local water systems to verify the accuracy of water supply and use data.

    e. Committing additional staff and resources to improving the states water use database.

    We recommend that the Legislature consider giving statutory authority to the Division of Water Resources to validate the annual water use reported by public water providers.

  • Office of the Utah Legislative Auditor General - 25 -

    Chapter III Conservation and Policy Choices Can

    Reduce Demand for Water

    The Division of Water Resources (the division) projects that Utahs demand for water will exceed its currently developed supply by 2040. This projection is based on the assumption that per capita water use will not decline after the year 2025 when the state is expected to reach its current goal to reduce water use by 25 percent. However, we believe, current trends suggest per person water use in Utah should continue to decline for the next several decades. If use does decline further, then the date when water demand exceeds supply may be delayed. In addition, water demand can be further reduced depending on how policy makers respond to certain policy choices. For example, policymakers should consider whether to require universal metering of secondary water and whether to further promote pricing structures that encourage conservation.

    Conservation Will Lead To Less Water Use

    We question the divisions projected demand for water, which assumes the average Utah resident will consume 220 gallons per day through the year 2060. The accuracy of this projection is uncertain for a number of reasons. First, the projected water use of 220 gpcd is based on a 2000 baseline water study, which, as described in Chapter II, may not be reliable because of a lack of documentation and methodological concerns. Second, other western states use less water than Utah, suggesting that Utah residents may be able to reduce their water use. Third, ongoing trends towards conservation should continue to reduce per capita water use by more than the states 25 percent conservation goal. The division has stated they intend to update the goal once it has been met.

    Accuracy of Water Demand Projections Are Uncertain

    The division relies on its 2000 M&I study as the basis for projecting the states future demand for water. The study was based on a survey of all public water systems between 1992 and 1999. Based on

    Chapter III examines the divisions estimates for future water use.

  • A Performance Audit of Projections of Utahs Water Needs (May 2015) - 26 -

    those surveys, the division determined that statewide water consumption was about 667,000 acre-feet in 2000. That equals about 293 gallons per person per day (gpcd). The divisions projection of future water demand assumes that each river basin will achieve the states conservation goal. That is, each basin will reduce water use by 25 percent by 2025, which will equal a statewide average use of 220 gpcd. When projected out to 2060, when the states population is expected to be 6 million, statewide demand for water will be nearly 1.5 million acre-feet per year. See Figure 3.1.

    Figure 3.1 Utahs Projected Municipal and Industrial Water Demand and Supply. The division projects that the demand for water in Utah will begin to exceed the current non-shared supply by about 2040.

    Source: Adapted from a Division of Water Resources figure.

    According to the above figure, even if the states conservation goals are achieved, the states currently developed supply will run out around 2040. From that point, the water supply deficit is projected to grow to 371,000 acre-feet by 2060. Concerns about the reliability of the states water use data, as discussed in Chapter II, not only undermine the reliability of the divisions water demand projections, but also contribute to uncertainty about progress toward the statewide conservation goal.

    According to division projections, the water supply deficit will grow to 371,000 acre-feet by 2060.

  • Office of the Utah Legislative Auditor General - 27 -

    We Question Whether 220 GPCD Is a Reasonable Goal. As reported in Chapter II, the accuracy of the divisions baseline water demand projection of 293 gpcd could not be validated. Because the states conservation goal assumes a 25 percent reduction of that amount by the year 2025, we are equally unsure if the statewide conservation goal is reliable. While we agree that water consumption rates have and will continue to decline, without reliable water use data, we question whether 220 gpcd actually is a reasonable goal. Better water use data would help us to conclude whether a lower or higher goal is achievable.

    The Divisions Current Goal Assumes Future Water Demand Will Not Continue to Decline after 2025. Using the states current conservation goal of reducing water use by 25 percent, the projection assumes that once this goal is achieved, no further reductions will occur after 2025. We disagree with this assumption. Figure 3.2 shows the divisions projection of daily per capita water use through 2060.

    Figure 3.2 Utahs Per Capita Water Use Projection by Year. The division assumes the states per capita water use will gradually decline to 220 gpcd by 2025 and remain at that level through 2060.

    Source: Division of Water Resources 2000, 2005, 2010 Municipal and Industrial Water Supply and Use Studies.

    Figure 3.2 shows water consumption rates declining until 2025, when the state conservation goal of 220 gpcd is projected to be reached, at which point, per capita water use will continue at that rate through 2060. Also shown (in blue bars) is the actual water use, as reported by the division, for 2005 and 2010, which shows the state is progressing well ahead of its conservation goal. Based on this data, the

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    Actual water use indicates that the state is progressing well ahead of its conservation goal.

    The division assumes that once the states water conservation goal is achieved, and water use is reduced by 25 percent, no further reductions will occur after 2025.

  • A Performance Audit of Projections of Utahs Water Needs (May 2015) - 28 -

    division appears overly cautious in projecting that water use will drop no lower than 220 gpcd for 35 years. Other states water use also supports the likelihood of future use reductions below 220 gpcd.

    Neighboring States Use Less Water and Have Lower Conservation Goals than Utah

    According to the U.S. Geologic Survey, Utah has the highest per capita water use in the nation. Figure 3.3 compares M&I and residential water use in Utah to that of other western states.

    Figure 3.3 A Comparison of Water Use Among the Western States. At 248 gpcd, Utahs municipal and industrial water use, as well as residential water use, is reported to be the highest of these 10 western states.

    Source: Estimated use of water in the United States in 2010: U.S. Geological Survey Circular 1405, 2014 Note: Use only includes water from public providers.

    We recognize there are unique climate conditions, different reporting methods, and other factors that can lead to different rates of water use from one state to another. However, the differences in water use shown in Figure 3.3 are so large that they raise questions about why the division should expect Utah residents to consume so much more water than the residents of neighboring states. If per capita water use in most other states is already well below 220 gpcd, it is difficult to justify the divisions current projection that Utahs water use will not drop below 220 gpcd after 2025.

    159 161 166 180 181

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    Utah has the highest per capita water use of western states.

    Most western states are at or below Utahs goal of 220 gpcd.

  • Office of the Utah Legislative Auditor General - 29 -

    We could not find many other states with conservation goals to compare to Utahs projected demand of 220 gpcd in 2060. Only California has a statewide conservation goal which is to reduce water use to 154 gpcd by the year 2020. However, we find one regional comparison that is insightful. The Southern Nevada Water Authority, which serves the Las Vegas region, has a goal to reduce water use to 199 by 2035. In contrast, the communities in Southwestern Utah, which have a climate that similar to that of Southern Nevada, have a goal to reduce water use to 292 gpcd by the year 2060.

    Conservation Trends Will Continue To Reduce Utahs Water Use

    Trends towards greater conservation suggest that per capita water use will continue to decline after Utah has reached its current water conservation goal of 220 gpcd. Research suggests outdoor water use in Utah is not very efficient. In addition, declines in residential lot sizes indicate a trend towards lower per-household use of outdoor water. Similarly, improved efficiencies of low-flow appliances suggest indoor water use can achieve further declines as well. Besides these examples, the division has identified an array of other conservation practices that will continue to reduce water use.

    Landscapes Still Receive Too Much Water. Even though the states Slow the Flow campaign seems to have helped reduce wasteful watering practices, USU researchers suggest there is still opportunity to reduce outdoor water use. The USU Center for Water-Efficient Landscaping conducted a 10-year study of outdoor watering practices in Salt Lake City. The researchers found that, as recently as 2010, residents were applying twice as much water as needed for their plants to be healthy. If instead, they were to use the efficient watering techniques recommended by the USU Center, the amount of water used for outdoor irrigation could be reduced by 26 percent.

    Trend Towards Smaller Lot Sizes Should Reduce Outdoor Water Use. Envision Utah is a regional planning organization that promotes quality growth in the state. It reports that, since 1998, the average lot size along the Wasatch Front has declined from 0.32 acres to 0.25 acres. Smaller lots should result in less irrigated landscaping. According to one of Envision Utahs urban planners, the trend towards smaller lots should continue as the states population grows.

    Declines in average lot size should result in less irrigated landscaping and a decline in outdoor water use.

    USU researchers found that residents were applying twice as much water as needed for their plants to be healthy.

  • A Performance Audit of Projections of Utahs Water Needs (May 2015) - 30 -

    Because 44 percent of M&I water use is for residential outdoor watering, a decline in average lot size will likely reduce the overall demand for water. However, a trend towards reduced household size may offset some of this reduction in per capita use.

    Low-Flow Fixtures and Appliances Will Continue to Reduce Water Use. The use of low-flow fixtures and appliances is one of several factors that led to the divisions belief that water use would decline by 25 percent. Based on a 1994 study, the division predicted a 7.5 percent decline in water use would be achieved as Utah residents installed low-flow toilets and showerheads. Recent information suggests that the water saved through use of low-flow fixtures and appliances may be even more than the divisions original estimate.

    Since 1994, other appliances, such as washing machines and dishwashers have also become more efficient. For example, the EPA reports that washing clothes represents nearly 22 percent of indoor water use and that new high-efficiency washers can reduce water use for clothes washing by nearly half. This means that, as outdated household appliances are replaced, indoor water use will continue to decline. This information is not reflected in the states current water conservation goal. In addition, the divisions original estimate of a 7.5 percent reduction in water use was based on a 1994 study of low-flow toilets and showerheads.

    Other Conservation Best Practices Will Continue to Reduce Water Use. The divisions water conservation plan identifies best management practices that include: outdoor watering guidelines and ordinances, commercial and residential water audits, retrofit, rebates, universal metering, incentive programs, and leak detection and repair programs. Although difficult to quantify, we believe these practices will continue to be implemented throughout the state and continue to reduce water use.

    In conclusion, opportunities to continue reducing per capita water use remain abundant. This information suggests a strong possibility that Utahs per person water use will continue to decline after 2025 and could be less than 220 gallons per person per day in 2060. Better data, thoroughly analyzed, is needed to inform policymakers.

    Recent information suggests that the water saved through use of low-flow fixtures and appliances may be exceed the divisions original estimate.

    Conservation efforts suggests a strong possibility that Utahs per person water use will continue to decline after 2025 and could be less than 220 gallons per person per day in 2060.

  • Office of the Utah Legislative Auditor General - 31 -

    Some Regions Can Reduce Water Use Beyond the Statewide Goal of 25 Percent

    Some river basins have the ability to reduce water use much more than the state goal of 25 percent. In fact, two river basins already met that goal by 2010, and two other regions have nearly met the goal. This is another reason we think the states long-term projected use of 220 gallons statewide is too high. Rather than applying the same 25 percent conservation goal to all basins, the division should establish a new set of conservation goals that reflect each regions unique conditions and ability to conserve.

    Division Has Already Established New Goals for Some Regions

    When the division completed its 2010 M&I study, two river basins had already achieved the states conservation goal to reduce water use by 25 percent. Those basins are the Kanab Creek/Virgin River Basin and the Cedar/Beaver Basin. In response, the division established a new conservation goal for both of those two basins. The new goal is to reduce water use by another 10 percent by 2060.

    The 2010 M&I study also showed that the Sevier River Basin and the Weber River basin had reduced their water use by 24 percent. However, even though those two basins nearly accomplished the statewide conservation goal, the division decided not to revise their goals until they had fully completed the goal to reduce water use by 25 percent. Thus, the division continues to project that these two river basins will reduce their water use by 25 percent by the year 2060.

    We believe these examples raise questions about the divisions approach to setting conservation goals and its use of those goals as the basis for projecting future water use in the state. The division began by applying the same statewide conservation goal to all river basins. Once a region met the goal, a new goal was set for that region. However, the statewide projection of water demand, which is based on the conservation goal, was not adjusted. In order to provide better long range projection of the states future water needs, the conservation goal should be established based on the best, most recent information available and then regularly adjusted as new information becomes available. The projected demand should then be updated to reflect the new goal as well. The division maintains that once the

    Two basins have already met the 25 percent water conservation goal prior to 2025 resulting in new conservation goals.

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    states goal has been met they will revise the goal and update water use projections.

    Water Use Projections Do Not Account for Each Regions Unique Ability to Conserve

    We are concerned that the divisions conservation goals do not reflect the unique ability of each regions ability to conserve. Rather than applying the same 25 percent goal to each region, the division should establish conservation goals on the unique conditions that drive water use in each river basin.

    Some River Basins Have a Greater Ability to Conserve than Others. By 2060, the division projects that some basins will still have much higher rates of water use than others. The reason is that the division assumes that each river basin should reduce its levels of water use by the same 25 percent goal, rather than considering each river basins unique circumstances and ability to conserve. Due to differences in climate conditions, types of industry, and outdoor watering practices, each river basin will have a different demand for water and a different capability to reduce that demand.

    Figure 3.4 shows the daily per capita water use each river basin will achieve in 2060 if it meets the states goal to reduce water use by 25 percent. The water use is broken down into three categories: (1) residential indoor, (2) residential outdoor, and (3) commercial, industrial, and institutional (CII) water use. The indoor use (in blue) is about the same for each region. Larger differences are observed in the residential outdoor use (in orange). In that category, West Desert Basin uses the least at 65 gpcd, while the West Colorado Basin uses the most at 153 gpcd.

    The third water category shown in Figure 3.4 is the water use by commercial, industrial and institutional users (in grey). The chart shows that water use by CII users is the lowest in the Jordan Valley Basin at 59 gpcd, while the Virgin River/Kanab Creek region has the highest at 150 gpcd. It should be noted that the Virgin River/Kanab Creek basin is the only one that includes water use at second homes in the CII category.

    Each river basin will have a different demand for water and a different capability to reduce that demand.

  • Office of the Utah Legislative Auditor General - 33 -

    Figure 3.4 By 2060, the Division Projects Large Differences in the Per Capita Water Use Among the River Basins. For most river basins, the projected water demand represents a reduction by 25 percent of each basins water use in the year 2000. For some basins, the goal has been increased to a 35 percent reduction of the 2000 water use.

    Source: Prepare 60, Roadmap of Utahs Future Water Development and Infrastructure.

    Some regional differences in water use should be expected. For example, one river basin may have larger residential lots, or a climate that requires more outdoor watering than others. However, there is also evidence that some of the differences point to greater opportunities to conserve.

    Weber River Basin Should Be Able to Make Additional Reductions in Its Water Use beyond the State Conservation Goal. The Weber River Basin is a region which appears to have a much greater opportunity to conserve than others. For this reason, the division should consider setting a more aggressive conservation goal for that river basin.

    The outdoor residential water use in the Weber River Basin is quite high when compared to other regions, mainly because of the regions high rate of secondary water use. The division reports that 70 percent of total outdoor water use in Weber River Basin is provided by secondary water systems. The users of those secondary systems

    53 53 53 55 54 54 53 51 51 55 55

    101131

    85 87 87

    14096 88

    122153

    65

    68

    76

    59

    150

    70

    90

    9367

    74

    78

    105

    0

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    GPC

    D

    Commercial, Industrial, Institutional Residential Outdoor Residential Indoor

    Weber River Basin use much more residential outdoor water than surrounding basins.

  • A Performance Audit of Projections of Utahs Water Needs (May 2015) - 34 -

    water pay a flat fee for virtually unlimited use of irrigation water. This practice has led to higher residential outdoor water use than in neighboring river basins. As shown in Figure 3.4, per capita residential outdoor water use in the Weber River Basin is 122 gpcd compared to 88 gpcd in Utah County and 85 gpcd in Salt Lake County.

    Because they have a greater opportunity to conserve, we think the division should expect a greater reduction in water use in the Weber River Basin than the Salt Lake or Utah Lake basins. In fact, the general manager of the Weber Basin Water Conservancy District agrees. He reports that unmetered secondary water use is the main reason water use is much higher in that river basin than in other basins along the Wasatch Front. Furthermore, he said that the district has begun to install meters on its secondary connections. As it does so, he predicts that the basins outdoor residential water use will drop below the current projections.

    Goals for the Kanab Creek/Virgin River Basin Should Be Based on an Analysis of Unique Conditions in That Region. The Kanab Creek/Virgin River Basin is another region that has unique conditions driving water use. As shown in Figure 3.4, the Kanab/Virgin River basin has high commercial, industrial and institutional use (or CII, shown in grey). The divisions water conservation goals and projected use should reflect these unique conditions.

    According to a local water district manager, the high rate of water use by visitors to the region is the main cause of the high CII water use in the Kanab/Virgin River Basin. Washington County has a large number of hotels, restaurants, golf courses, and second homes. Those facilities serve visitors who consume water but do not permanently reside in the area. The division should consider whether visitors water use will grow at same pace as use by the regions permanent population. Ideally, the divisions projection for the demand in the Kanab/Virgin River Basin should reflect a separate analysis of the likely growth in the CII category, rather than just assuming it will be proportionate to the growth in the permanent residential population. By considering the unique conditions that drive water use in a region, the division can improve the accuracy of its projections of Utahs future demand for water.

    Water use in the Kanab Creek/Virgin River Basin is affected by the large number of tourists who visit the area and by the prevalence of second homes.

  • Office of the Utah Legislative Auditor General - 35 -

    Division Should Not Wait to Update Its Projections of Future Water Use

    The division has acknowledged that water use will likely decline after the current conservation goal is met. The division reports, it appears the 25% conservation goal will be met soon. The division also reports that they plan to wait until the current goal is reached [before] another goal will be implemented. However, we believe if the goal does not reflect their current expectations for the states future water use, then the division should update its projections.

    State policy makers have recently been presented with a proposal that the state establish financing for billions in new infrastructure projects. The division should provide them with the most up-to-date, accurate projections regarding the states future water needs. Next year, the division will conduct a new statewide water study for 2015. The 2015 M&I study should be used to establish new water conservation goals that reflect each basins ability to reduce its water use as well as new projections of each river basins water needs.

    The timing for developing costly new infrastructure projects is uncertain and depends on changing water use patterns, and population estimates. Climate change is also an important consideration, according to the division. As new water use information and population estimates become available, the division should update its projections of future water demand accordingly. A range of projections, as recommended in the 2014 Utah Foundation Report2, could help the division better plan for Utahs future water needs by anticipating future water demand under a range of different population projections and water use levels. Scenario forecasting will improve planning efforts by pinpointing when costly projects that add additional water supply are needed.

    State Policies on Metering and Pricing Can Affect Water Demand

    Utah is fortunate to have some of the lowest-priced water in the nation. Historically this is due, in part, to a favorable climate and a gravity fed delivery system that is relatively close to much of Utahs

    2 Utah Foundation, Flowing Towards 2050, September 2014

    The division will wait to change the states conservation goal once the current goal has been reached.

  • A Performance Audit of Projections of Utahs Water Needs (May 2015) - 36 -

    population. Pressures on Utahs currently developed water supply are projected to intensify with population growth. Unless water demand is reduced, new sources of supply will need to be developed and delivered from greater distances, resulting in increased costs. Given these costs, policies aimed at reducing per capita water use need to be prioritized.

    Policymakers have a variety of options for reducing per capita water use. One option is to require the metering of all water service connections, including secondary connections. Metering promotes water savings through bette